Bayer Corporation - Baytown, Texas Plant - Executive Summary
Bayer Baytown |
Accident Release Prevention
Bayer Corporation considers its responsibility to protect the environment and the health and safety of its employees, customers, and communities of primary importance in the conduct of its business.
Every Bayer employee is responsible for working safely. Safety is a primary responsibility of all levels of management and supervision and they are expected to set an example by their behavior.
Bayer is committed to the safe operation of its facilities and will design, operate, maintain, and regularly inspect facilities to safeguard employees and the public. Bayer's goal is to make its operations safer by continuos improvements in safety and health measures.
"Responsible Care" is a public commitment to which the Bayer Baytown Plant pledges wholehearted support. This initiative of our company, and other members of the Chemical Manufacturers Association, is designed to continuously improve the health, safety and environmen
tal performance of all companies.
The Bayer Baytown Plant is a Star rated facility in the OSHA Voluntary Protection Programs.
We will strive for Safety, Health, and Environmental excellence while supporting our customer's, corporate, and site objectives.
Description of the Facility
The Bayer Baytown facility is located two miles east of the city of Baytown and five miles south of the city of Mont Belview, Texas. It is situated in a former rice field. The facility is centered on approximately 1200 acres of which approximately 50% have been built.
The Bayer-Baytown facility is primarily a manufacturing site. Services and support are on site to support the manufacturing needs. The facility is comprised of several different manufacturing divisions within the Bayer Corporation.
All manufacturing processes are located on contiguous property and are managed by the same corporate organization. The Bayer Baytown site is considered a stationary source.
The site is serviced by highw
ay, rail, pipeline, and barge supply routes or product outlets.
The Bayer Baytown facility operates to produce various products across the plant. Products are used in the production:
* of coatings and paint products (polyurethane coatings),
* of flexible foams (seat padding), semi-rigid foams (automobile fascia, athletic shoe soles), and rigid foams (insulation sheets),
* of thermal plastics (compact disks - CDs),
* of intermediates to be used in manufacturing herbicides and pesticides, and
* organic intermediates used in the manufacture of resins and plastics (boats).
The Baytown plant has ten covered RMP processes. The entire site has been defined as a Process Safety Management site by the Bayer Baytown management. All processes are covered at the full PSM level. For the scope of Risk Management, all covered processes are considered to be Program Level III processes.
There are ten covered chemicals which are in use at quantities greater than the threshold quantity defined in
the RMP regulations. These ten chemicals are:
* Ammonia solution (greater than 20%)
* Ethylene oxide
* Formaldehyde solution (37%)
* Hydrazine (only exists as an intermediate step in one process)
* Propylene oxide
* Toluene diisocyanate (mixed isomer form).
There are several other chemicals in use in the Baytown Plant which are covered (anhydrous hydrogen chloride and hydrogen), but exist in quantities significantly below the threshold quantities.
Hazard Assessment Results
The Baytown plant used the EPA supplied consequence analysis guidance documents to assess the offsite impacts of the scenarios evaluated. The scenarios selected are adequately covered by these documents.
The Worst case Scenario for toxics involve the release of a toxic material from the largest vessel in the process. The release, by EPA definition, can not have any mitigation systems operate and no operator is allowed to intervene. The release is assumed to occur and a
llowed to proceed until all of the source material is released. The worst case, under these definitions, is a release of a full tank of chlorine which would have an off site consequence.
The worst case for flammable materials is similar. The release considers the largest vessel is completely full. All the contents are released instantly, vaporized instantly, and detonated instantly. The distance to a one-psi over-pressure is considered the worst case distance.
Although there are numerous safeguards to prevent such an incident, the worst case scenario at Bayer Baytown would be the release and detonation of a full tank of butane. The distance to the EPA specified end-point would be off site a small distance.
The EPA guidelines specify that an alternate release scenario must be developed for each toxic material and one for all flammable materials. These alternate release scenario must have an off site consequence unless one does not exist and must be useful for emergency planning
by the local emergency responders.
Each covered toxic material was assessed to identify a release scenario which does provide an off-site consequences regardless of the numerous safety systems in place to prevent any release from leaving this plant area. The alternate release scenarios for toxics at the Bayer plant include:
* Ammonia: a leak in a plant pipe system
* Ammonia solution: a leak in a plant pipe system
* Chlorine: a leak in a plant pipe system
* Ethylene oxide: a leak in an unloading system pipe
* Formaldehyde: a leak in a plant pipe system
* Hydrazine: a leak in the pipe system (at a specific process step)
* Phosgene: a leak in a plant pipe system
* Propylene oxide: a leak in an unloading system pipe
* Toluene diisocyanate: a leak in a vessel.
The leak sizes and duration of each of these was adjusted until an off site consequence was reached.
Each covered flammable material was analyzed to develop a release scenario which does provide an off-site consequences regardle
ss of the numerous safety systems in place to prevent any release from leaving this plant area. The alternate release scenarios for toxics at the Bayer plant include:
* Butane: a leak in a vessel (leading to a vapor cloud fire).
The leak sizes and duration of each of these was adjusted until an off site consequence was reached.
Management of Risk
The Bayer Baytown plant has defined each of the processes as covered by Process Safety Management. To adequately control the hazards presented in each process:
* Employee Participation
Employees are provided opportunities to participate on numerous safety steering committees which affect the worklife of each area at the Bayer Baytown site. Participation in these organizations is encouraged. All identified action items from inspections, incidents, process hazards analyses, etc. are provided to personnel for review. Involvement of personnel in the OSHA-VPP program has been exceptional. Personnel particpate in all PSM-releated activities
* Process Safety Information
All Bayer personnel on this site have access to the electronic mail system and company Intranet. Access is provided to chemical specific information (MSDS), operating information, and information on the equipment in the process. The information resides in an electronic system which is updated regularly. All PSI is verified at each scheduled PHA.
* Process Hazards Analysis
Process hazards analyses are conducted in each process on a five-year basis. The HazOp method is used to conduct the PHA. Findings are identified, prioritized and corrected in a timely manner. The action items and completion schedules are available through the electronic system.
Operating procedure which address all of the normal and non-normal operating situations are in place. Deviations from established operating limits and the consequences of these deviations are clearly identified and easily referenced. The procedures are reviewed annually to assure
they are accurate and current.
Training on these operating procedures is conducted on a regular basis to assure that operators know and understand the safe operation of their unit and to understand what actions are necessary in non-normal situations. Training is documented through a network system. The system allows determination of training needs as well as completion of required training subjects.
Control of contractors in the operating areas has been established. A safety steering committee and safety council has been put in place to continually monitor the actions of contractors to assure their safety as well as the safety of the Bayer plant.
Pre-startup Safety Reviews
Reviews are conducted of any new facility, major modification, or a change (management of change) before the new system is put into operation. Any findings are addressed prior to the startup.
Mechanical integrity procedures are in place to assure that maintena
nce workers understand how to safely perform the duties required to maintain the facility. Specific instructions for testing and inspections are included. Testing and inspections are conducted as scheduled and documented. Maintenance and engineering follows established codes, standards, and company guidelines.
Hot Work and Control of Abnormal Activities
Control of hot work and abnormal situations is conducted to assure that work in the workplace does not contribute or cause hazardous results. All aspects of hot work and abnormal situations are controlled.
Management of Change
Change is managed properly. All changes generate an appropriate assessment of possible impacts on the level of safety and health on an area. All necessary documents and procedures are changed. Personnel are informed regarding the change before they are required to operate the new system.
Incidents, accidents, and near miss situations are investigated. Root causes are identified.
Changes are made in the system to assure that the incident will not occur again. Incident reports are made available to be used in informing others in the plant.
The Baytown conducts compliance audits of the entire site PSM program every three years. An audit team made up of hourly, supervision, and contractors conducted the last audit. Deficiencies identified are corrected in a timely manner. Open action items are tracked to completion.
Chemical Specific Prevention Programs
Accident prevention programs are required in each process in the Bayer Baytown site. Specific prevention programs include:
Detectors are in place for various toxic vapors (phosgene, chlorine, ethylene oxide, propylene oxide, etc.).
Detectors are in place for hydrocarbons (butane).
Personnel wear dosimeters in the plant
LDAR program is in place
Personnel making operating area observations
Release Control and Containment:
Emergency scrubber systems
um neutralization systems
Remote operated valves to contain systems/process
Relief devices directed to neutralization systems
Steam-ammonia curtains surrounding operating areas
Fire water monitor systems
Release Mitigation Systems:
Trained emergency response personnel
Emergency response support organizations
Fire/toxic release suppression and fire extinguishing systems
Deluge systems for specific areas
Appropriate personnel protection equipment
Five Year Accident History
The Bayer Baytown plant has an excellent record of accident prevention and release containment. There have been no RMP defined accidents with either onsite or offsite injury or damage in the past five years.
Emergency Response Program
The Bayer Baytown maintains an onsite trained emergency response team. Each shift has an emergency response team. The team has all required training. There are emergency medical technicians on each shift. There is an ambulance and fire truck maintained for use on site.
There is also a prepared trailer to provide additional equipment (air bottles, escape equipment, etc.) during an emergency.
The emergency team includes members who have completed requirements for hazard materials (HazMat) response. There is prepared equipment for emergency HazMat use in this facility.
There is a designated organization to respond both during daytime emergencies and off-shift emergencies. The incident command center has all necessary equipment (maps, warning systems, P&ID drawings, MSDS, etc.) and supplies to direct the response. The center is also equipped with an emergency response modeling system (Safer) to anticipate effects of a release on other areas of the facility as well as the community. The incident command center maintains lists of personnel to notify during an emergency. The list includes local emergency response personnel and organizations.
The Bayer Baytown facility is active in both the Channel Industries Mutual Aid (CIMA) and the Mutual Aid
Mont Belview organization. The Bayer facility is an active participant in the Baytown Local Emergency Planning Committee. All emergency plans have been coordinated with the Baytown LEPC. The Bayer facility has also been involved in the reactivation of the Chambers County LEPC. All RMPlans have been reviewed with both LEPC groups. Community outreach efforts are currently underway in all communities in the vicinity of the Bayer facility.
The Bayer facility has also been an active participant in the Baytown Citizens Advisory Panel. In response to this organizations' request, the City of Baytown is notified of all plant level alarms. This gives citizens a source of information. The East Harris County Manufacturing Association maintains a CAER line for information purposes. The Bayer facility is a participant in recording messages in the event significant activities is occurring in the Bayer facility.
The Baytown Plant Managers Network represents all of the manufacturing industr
y in the Baytown area. Through this organization, a community alert siren system was installed several years ago. Currently, the system is being enlarged to cover more of the Baytown area (out laying areas).
The Bayer Baytown facility fully participates in the CMA Responsible Care program.